MS4 Permit Updates May 9, 2014 Jay Hoskins, P.E. Metropolitan St. Louis Sewer District

MS4 Permit Updates 1. MS4 Permit Renewal 2. 3 rd Term Permit Stormwater Management Plan Highlights 3. Federal Rulemaking 4. Show-Me Rain Gardens Website

MS4 Permit Renewal 2 nd Term Permit expired June 12, 2013 MDNR has proposed, but not issued, a 3 rd term MS4 general permit 2 nd term permit is administratively continued Key issues in proposed permit Water quality standards in MS4 permits TMDL implementation Affordability

Water Quality Standards (???) CWA: Permits for discharges from municipal storm sewers…shall require controls to reduce the discharge of pollutants to the maximum extent practicable, including management practices, control techniques and system, design and engineering methods, and such other provisions as the Administrator or the State determines appropriate for the control of such pollutants.

TMDL Implementation No MSD streams have EPA approved TMDLs, at present Proposed permit requires The permittee develop a TMDL Plan within 30 months following EPA approval of a TMDL “Plan to address TMDL assumptions, requirements, WLAs, and LAs” “Permittee must implement the plan”

Affordability MO statutes require MDNR perform a Finding of Affordability for new permit requirements MDNR’s finding only addressed TMDL plan development—not implementation “TMDL implementation responsibilities are not new requirements.” Recently, MDNR managers agreed to revise this position and perform the affordability determination for plan implementation, in the future

Ongoing MS4 Permit Activities Continue to implement 6 MCMs… Public Education & Outreach Public Involvement & Participation Illicit Discharge Detection & Elimination Construction Site SW Control Post-Construction SW Mgt in Development P2/Good Housekeeping for Muni Ops Submit annual report by July 28 Co-permittee group tabling most 3 rd term SWMP activities until permit is renewed

3 rd Term Permit Planning Process 7 planning committee meetings 3 public stakeholder group meetings 3 newsletter publications New goal development Researched new BMPs MDNR audit recommendations Draft SWMP public Notice in October 2012 Final SWMP mailed to MDNR in December 2012 Available on MSD website

3 rd Term Permit Plan: New Goals Develop standardized checklists and reporting procedures for post-BMPs DONE—see BMP toolkit Redevelopment Roadway Workgroup Begun—not finished Workgroup on incentives & awards for participating in NPS reduction programs Begun—not finished Ask cities to review, update parking ordinances (as needed) Legal Impediment WG Recommendation

3 rd Term Permit Plan: New Goals Workgroup on improving NPS education in schools Develop and distribute brochures on individual sewage disposal systems Develop and conduct “staged” construction BMP inspection training Updating municipal O&M model template, ask cities to update plans Review BMP performance for bacteria, chloride

Federal Stormwater Rulemaking EPA Finalized “Construction and Development Effluent Guidelines and Standards” Effluent limits reflecting best practicable technology currently available: “Control stormwater discharges, including both peak flowrates and total stormwater volume” “Provide and maintain natural buffers around waters of the United States, direct stormwater to vegetated areas and maximize stormwater infiltration to reduce pollutant discharges, unless infeasible” Withdrew numeric turbidity standard EPA has deferred development of national post- construction BMP performance standard

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Questions? Jay Hoskins (314)